Te Rito Maioha Responds To Regulatory Review Of Early Childhood Education (ECE)

The review conducted by the Ministry of Regulation has thoroughly traversed the issues raised by the more than 2,300 submissions. However, there are some red flags within the 15 recommendations that require unpacking, especially where the recommendations have moved from concerns about poor regulation to fundamental issues that support quality ECE, such as teacher qualifications.

“The good news is that the voices of ECE professionals have been heard,” says Kathy Wolfe, CE of Te Rito Maioha, “and the issues associated with regulations and their uneven application have been highlighted.”

“However, there is unease where the recommendations move from overzealous regulations, to focus on issues such as affordable access to quality ECE and the ongoing teacher shortages. Here, the solutions are not underpinned by evidence that supports quality ECE, but rather market-driven solutions that are not backed by evidence.”

“The attempt to regulate the ECE market with Network Planning was the previous government’s effort to ensure that ECE Centres were not set up where there was already adequate supply. In practice, the implementation and application was burdensome and not transparent.

“Likewise, the recommendation to ‘allow greater flexibility in workforce qualifications to support access and quality across all areas and service types’ has the potential to make the problem it is trying to fix, worse.”

“Quality ECE is underpinned by qualified teachers, the time and quality of their interactions with the children, and a safe and supportive structure around those interactions.”

“To remove the need for qualified teachers or “dumb down” qualifications does not solve the teacher shortage! The appropriate response to staff shortages is to put in place an effective ‘teacher education workforce strategy’. That means supporting the teaching profession by ensuring initial teacher education is robust, committing to attraction and retention of qualified teachers and focusing on conditions such as pay parity.”

“You certainly won’t encourage people to become teachers by telling them that the profession of teaching doesn’t require teachers! This has the potential to become a short-term fix that undermines the profession of teaching while shifting the quality New Zealand ECE experience, towards a lower cost, but ultimately lower quality model.”

“It also flies in the face of overseas experience where if we look across the ditch, our Australian counterparts are investing heavily in qualified ECE teachers. Australia have taken a long-term view - with significant investment and drive to attract ECE teachers. Not just addressing teachers’ pay, but lifting the profession by showing they're valued which means better career options, better pay and better working conditions. Ironically, they looked to us for this aspiration.

Many countries that had a split or two-tiered system (separating care of infants/toddlers from care and education of 3-4-year-olds) are moving towards an integrated education system like ours. That includes looking at teacher qualifications.

The Ministry’s Review includes some important qualifications to the recommendation to allow greater flexibility in workforce qualifications. On page 79 at point 224, the Ministry writes that:

‘The Ministry of Education notes that care should be taken in considering qualification requirements separately from other requirements that influence outcomes for children, such as ratios, group sizes and supervisory roles (e.g. person responsible). Other countries may balance lower qualification requirements with higher ratios or different supervisory roles.’

Further at point 326, the Ministry notes:

‘From our review of international comparisons, it appears as though the approaches taken internationally strike a better balance of ensuring quality and accessibility of ECE. However, a full cost-benefit analysis comparing New Zealand’s approach with international examples would be needed to determine this conclusively, because there is evidence to show otherwise.’

“That the Ministry’s own paper recognises their recommendations are based on a best guess rather than a benefit analysis is very concerning,” says Mrs Wolfe. Depending on how this recommendation is presented in the Cabinet Paper scheduled for early 2025, New Zealand could shift from quality ECE, to an approach with less than desirable education delivery and outcomes.”

The Minister of Education is looking for improved educational outcomes for children in Aotearoa New Zealand. To achieve this, we must invest and keep placing quality ECE for our tamariki at the centre of decision making, and we, like the rest of the sector remain willing to help with the design, testing, and implementation of any changes to ensure regulations are fit-for-purpose and there are no unintended consequences for our tamariki’s education.”

“This is just too important not to get right.”

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